Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:07-cv-00166-CCM

Document 25

Filed 10/01/2007

Page 1 of 1

IN THE UNITED STATES COURT OF FEDERAL CLAIMS PAUL E. DOLAN Plaintiff, v. ) ) ) ) ) ) ) ) ) ) )

Civil Action No. 07-166C (C.O.C.Miller)

THE UNITED STATES Defendant,

PLAINTIFF'S CONSENT MOTION FOR LEAVE TO FILE OUT OF TIME PLAINTIFF'S HIS REPLY TO DEFENDANT'S OPPOSITION TO THE MOTION FOR RECONSIDERATION Plaintiff-Dolan, in an abundance of caution, moves for leave to file out of time by 1 day to September 28, his reply to defendant's opposition to Dolan's motion for reconsideration. Dolan's reply was due September 27. He submitted his reply at midnight on the 27th, however due to the 2 hour time difference from Eastern and Mountain time, it is entered as 0200 AM on the 28th. Moreover, counsel was delayed from filing his reply earlier that day. A family work emergency arose with counsel's wife's national guard duty to plan a soldier's funeral. This required counsel to care for his twin infants. Opposing counsel was contacted concerning this motion, and she consents. WHEREFORE, in the event the Court requires leave to file Dolan's reply, then plaintiff respectfully requests that the Court grant leave of 1 day to 28 September to file his reply to defendant's opposition to the motion for reconsideration.

October 1, 2007

Respectfully submitted,

a/s John A. Wickham Counsel for Plaintiff-Dolan 32975 Saint Moritz Drive Evergreen CO 80439 303 670-3825